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INTEROFFICE MEMORANDUM <br />TO: <br />ROB ZUBER <br />FROM: <br />JANET BINNS <br />SUBJECT: <br />SOUTHFIELD MINE, RN06, ADEQUACY RESPONSE REVIEW <br />DATE: <br />7/02/2014 <br />ATTACHMENT: USF &WS T &E SPECIES LIST FOR MINE AREA <br />I have reviewed Energy Fuels Coal, Inc.'s response to the Division's 1\1arch 28, 2014 preliminary <br />adequacy review for the Southfield I\ fine Permit Renewal No.6. <br />Items that I had identified as needing additional information correlate with numbers 8, 9, 10, 11, <br />14, 15, 16. <br />8. The baseline description of 2.04.10 Vegetation Information states on page 2.04.10 -1 of the <br />PAP, "The disturbance within the Southfield mine area comprises two (2) distinct areas, the refuse <br />disposal site and the portal area. The vegetation type disturbed at the refuse disposal area is <br />Grassland while the mine portal area is situated within the Ponderosa Pine - Pinion - Juniper Woodland <br />vegetation type." Page 2.04.10 -3 of the PAP further states, "At the mine site, the mine portal area will <br />primarily affect the Ponderosa Pine-Pinyon-juniper Woodland vegetation type." (PPJ) This <br />description doesn't completely agree with the illustration of the pre - mining vegetation shown on <br />1\Iap16. Map 16 shows significant pre - permit disturbance at the portal area, as well as a portion of <br />the pre - mining area mapped as grassland in addition to PPJ. This section of the permit is not out of <br />compliance. EFCI chooses not to clarify the general description of the portal area pre - mining <br />vegetation. The Division has no further comment. <br />9. EFCI's response to item No. 9 adequately addresses the Division's concern. <br />10. EFCI submitted an incomplete application to establish a replacement loadout reference area <br />on klay 1, 2014. The application provided no supporting data to allow the Division to evaluate if the <br />proposed loadout reference area was adequate. The application was deemed incomplete on May 2, <br />2014. A letter was sent to EFCI on May 5, 2014 explaining the information necessary to complete <br />the application. Division has not yet received any additional information regarding TR41. This item <br />remains unresolved. EFCI has stated that the approved loadout reference area was disturbed by a <br />third party. EFCI needs to establish an approved loadout reference area or reclamation standards in <br />accordance with Rule 4.15.7(2)(d). <br />11. The Division accessed the most current T &E species list for the Southfield Mine area from <br />the USF &W service website, on July 2, 2014. Five endangered animal species were identified as <br />needing to be considered for effect analysis for the reclaimed mine area. None of these species had <br />previously been identified in Table 29, or exhibit 12 in the permit. The mine is mostly reclaimed, <br />with a few minor area still requiring reclamation; sediment ponds, substation, water monitoring wells, <br />etc. Based on the current USF &WS T &E species list, and the mine baseline wildlife identification, <br />the Division finds the PAP in compliance with Rule 2.05.6(2) (a) (iii) (A). I am including the current <br />T &E species list for the operator. <br />